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Transparency & Trust: Aviation Emissions Verified

ReFuelEU Aviation

ReFuelEU Aviation

The European Union is working towards its emissions reduction target of 55% by 2030 through the Fit for 55 package, which includes the Regulation (EU) 2023/2405, known as ReFuelEU Aviation, adopted on 31st October 2023. This regulation penalises economic tankering to avoid emissions related to extra weight, and mandates fuel suppliers to provide a minimum share of Sustainable Aviation Fuels (SAF) at Union Airports.

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Why choose Normec Verifavia?

  1. Ensure compliance: Our meticulous verification services ensure compliance with applicable regulations, transparency, and prevent penalties and legal consequences.
  2. Unmatched Expertise: Our team of aviation experts ensures a thorough and accurate verification of emissions data and related parameters.
  3. Minimise compliance risks: Ensure regulatory confidence and minimise compliance risks with our trusted verification process.
  4. Company’s Experience: Normec Verifavia has more than 10 years of expertise in validation, verification, and auditing within the aviation sector, delivering the highest standards of services.
  5. Established verification programme:For ReFuelEU, we have established a Verification Program (reference: ReFuelEU Verification Program v.1 – August 2026), which is shared with our clients prior to the engagement phase.

Eligibility & Threshold

The ReFuelEU Aviation Regulation applies to aircraft operators, aviation fuel suppliers, Union airports, and their managing bodies. It includes aircraft operators that, in the previous reporting period, operated at least 500 commercial passenger flights or 52 commercial all-cargo flights departing from Union airports. A Union airport is defined as one that handles more than 800,000 passengers or over 100,000 tonnes of freight annually. Entities that meet these thresholds are required to comply with the regulation’s core obligations, including minimum SAF uplift, access facilitation, and reporting requirements.

Exemptions & Exclusions

Aircraft operators may request a temporary exemption from the 90% fuel uplift requirement for specific routes under 850 km, or under 1,200 km for island airports without rail or road connections, as measured by great circle distance (GCD). These requests must be submitted through the EASA Sustainability Portal at least three months before the reporting period. Certain flight types, such as state, military, humanitarian, medical, training, and return flights, are excluded from the reporting requirements of ReFuelEU Aviation.

 

Timeline and Phases

Aircraft operators are required to complete their annual reporting in a timely manner. A key deadline in this process is 31st March, by which the final report must be submitted through the EASA Sustainability Portal. This report includes details on fuel uplift and the use of sustainable aviation fuels (SAF) for the monitoring year.

SAF Requirements

Fuel suppliers are obligated to ensure that aircraft operators have access to Sustainable Aviation Fuel (SAF) at Union airports. At the same time, aircraft operators must ensure that the same batch of SAF is not double-counted under multiple schemes, maintaining transparency and integrity in SAF reporting and compliance.

Standards and Technical Guidance

The Standards and Technical Guidance under ReFuelEU Aviation include Regulation (EU) 2023/2405, which ensures a level playing field for sustainable air transport by setting SAF requirements. The Commission’s Interpretative Guidelines clarify exemptions under Article 5, and the Manual for Aircraft Operators and Verification Bodies provides practical instructions for compliance, reporting, and verification.

Interested in learning more about RefuelEU Aviation?

Gain exclusive access to our recorded RefuelEU Aviation webinar session held on 10th December 2025, where Normec Verifavia experts explain the key requirements, scope, and next steps for operators and regulated entities.

Complete the form below to receive temporary access to the webinar recording for a period of one week.

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Streamlined Compliance Process:

  1. Pre-engagement

    Our commercial team engages with the client. Thereafter, a pre-contract is elaborated and sent to the client.

  2. Engagement

    During the engagement stage, clear objectives are set with the client, which involves the comprehensive definition of the operational scope, ensuring that all relevant parties have a clear and shared understanding of the verification boundaries. The engagement is formalized through a contract, setting the stage for a structured and transparent verification process.

  3. Planning

    The verification activities are determined and planned based on the claims. An Audit Preparation Letter (APL) is sent to request all the required data and documents to begin the verification process. A strategic and risk analysis is performed to assess the risks and prepare a verification plan.

  4. Execution

    A thorough analysis of emissions data and supporting documents to verify accuracy, completeness, and consistency. The process ensures compliance with relevant regulations. It includes cross-checking flight and fuel data, reviewing monitoring methodologies, and validating control systems to confirm the integrity of the reported information.

  5. Review and Decision

    An independent technical review is conducted in accordance with ISO 17029:2019 and ISO 14065:2020 standards. After achieving reasonable assurance, a verification report is issued, ensuring that the client’s report is free from any material misstatements.

  6. Post-Verification Activities

    If there is any significant information that comes to light after the verification opinion has been issued and if such information could impact the verification results, it may necessitate a reassessment or correction in the report.

Downloads

Regulation (EU) 2023/2405 of the European Parliament and of the Council of 18 October 2023 on ensuring a level playing field for sustainable air transport (ReFuelEU Aviation) ReFuelEU Aviation Template for Aircraft Operators List of Union airports established for the purpose of ReFuelEU Aviation List of competent authorities of the Member States responsible for enforcing the application of ReFuelEU Aviation ReFuelEU Aviation Brochure List of aircraft operators in-scope of ReFuelEU Aviation
FAQ

Find answers to the most commonly asked questions

Who has obligations under the ReFuelEU Aviation?

The ReFuelEU Aviation is applicable to aircraft operators that operate flights from Union airports. The applicability threshold is based on the number of flights operated in the previous reporting period (1st January until 31st December). Obligations apply to operators that during the reporting period, have operated at least: 

  • 500 commercial passenger air transport flights departing from Union airports or 
  • 52 commercial all cargo air transport flights departing from Union airports. 

What are the obligations for aircraft operators under the ReFuelEU Aviation Regulation?

Aircraft operators must ensure that the flights departing from Union airports are refuelled with the necessary fuel for the flight. Article 5 of the ReFuelEU Regulation requires that the yearly quantity of aviation fuel uplifted by a given aircraft operator at a given Union airport shall be at least 90% of the yearly aviation fuel required. 

What information has to be reported?

As stipulated in Article 8 of the ReFuelEU Aviation Regulation, each year and for the first time in 2025, aircraft operators must submit a verified report to the respective Competent Authority by 31st March Year N+1 annually. The report includes the following: 

Fuel reporting: 

  • Total flight operated departing from a Union airport (in number of flights) 
  • Total flight hours operated departing from a Union airport (in number of hours) 
  • Yearly aviation fuel required (trip fuel and taxi fuel) at each Union airport (in tonnes) 
  • Total actual aviation fuel uplifted at each Union airport (in tonnes). 
  • Yearly non-tanked fuel quantity at each Union airport (reported as 0 if it’s negative or ≤ 10% of fuel requirements) 
  • Yearly tanked fuel quantity for fuel safety rules at each Union airport (in tonnes). 

SAF purchase reporting: 

  • Total Sustainable Aviation Fuel (SAF) purchased from suppliers for regulated flights (in tonnes) 
  • Details for each SAF purchase, including supplier name, batch number, quantity (tonnes), fuel category, feedstock, and lifecycle emissions. 
  • Eligible SAF claimed under EU ETS, CH ETS, CORSIA and other Market Based Measures (in tonnes) 
  • Eligible SAF not claimed. 

Declaration: 

A declaration that the aircraft operator has not claimed under more than one greenhouse gas scheme identical batches of SAF. 

What penalties apply for non-compliance?

There are no penalties for the 2024 reporting period, however, from 2025, if an aircraft operator does not meet the requirements set up in article 5 of the ReFuelEU Aviation Regulation (minimum uplift of 90% of the required fuel), penalties will apply. Member States will establish the penalties, these will be at least double the product of the yearly average aviation fuel price and total yearly non-tanked quantity. 

What happens if an aircraft operator cannot comply with the minimum of 90% due to fuel safety rules?

Fuel tankering might occur to comply with fuel safety rules (in line with Commission Regulation (EU) No 965/2012). In such cases tankering is justified by safety reasons; however there are specific circumstances, for example: 

  1. cases of fuel shortage 
  2. fuel contamination at the destination airport confirmed by a Notice to Airmen or Notice to Air Missions (NOTAM) 
  3. specific operational difficulties for some aircraft operators at some airports: in terms of disproportionate longer turnaround times for aircraft or reduced airport capacity at peak times. 

If the aircraft operator faces such cases, the aircraft operator should give an indication of the Union airports and flights impacted in the report to be submitted to the competent authority.  

Do aircraft operators need to meet minimum SAF uplift requirements?

No, the RefuelEU Aviation Regulation requires fuel suppliers to ensure that the aviation fuel available at Union aiports has a minimum SAF share. Aircraft operators’ obligations are related to avoiding economic fuel tankering practices. However, as SAF will become more accessible, thanks to the mandate to suppliers, aircraft operators will eventually uplift aviation fuel which includes the minimum shares of SAF. 

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